Privacy policy

1. Information we may collect
Personal  information or personal data is any information which can be used to identify an individual. This excludes data where the identity has been removed (anonymous data).

1.1 Your Personal data

  1. We respect your right to privacy and will only use the personal information you provide us with, we receive from your smart 
    meter, or that we receive from another organisation, such as credit reference agencies, as allowed by the Data Protection Act 1998 and other applicable privacy laws.
  2. We may monitor and record any of your communications with us, including telephone conversations and emails, to make sure we’re giving you a good service and meeting our regulatory and legal responsibilities.
  3. If you have any questions about the information we are holding about you and how we use it, or believe that the information we have about you is wrong or needs to be updated, please contact our customer services team.
  4. We will provide you with a copy of the personal data that we hold about you if you ask for it, although we may charge you a fee for manifestly unfounded or excessive request.  You can also ask us to update and correct any incorrect personal information which we hold about you, which we will do free of charge.

 

1.2  Information you give us.
During the course of entering a contract for energy supply with Iresa Limited, the information you give to us may include

1. Identity Data such as your full names, gender, date of birth. If you add a secondary account holder, the information you give to us may also include the full names, gender and date of birth of your secondary account holder.

2. Contact Data such as your house address, email address and telephone number. This may also include the email address and telephone number of a secondary account holder. We also keep records of when you get in touch by phone, email, social media and review those communications so that we can provide you with the required service and show evidence of interaction or events.

3. Transaction Data such as your transaction information holding payments you make for energy supply or services. This data also includes charges for energy use, for meter installation or other services rendered as communicated to you by the terms of your contract. We also keep records of payments made to you, refunds paid from payments made, cheques issued to you and compensation payments.

4. Vulnerability Data such as disabilities, age or health related conditions for you or any member of your household. This data includes that which you provided to us at sign-up and any additional entry you include from your online account, by email or phone communication. This helps us to provide suitable additional services to you.

We do not collect any special categories of personal about you like your political opinions, sexual orientation, race, religious or philosophical beliefs, ethnicity, biometric or genetic information.

1.3 Information we receive or collect from other sources.
We work closely with third parties (for example paper mailing, direct debit payment, meter reading, meter information, supply number search providers) and may receive the following information about you.

  1. Technical Data such as your supply address, meter reference numbers, meter type and meter readings. We use this to link you up with the right information and keep the industry databases up to date.
  2. Usage Data such as information about how you use energy. This may also include historical information about the trend of energy usage for your property. We need this information to send you accurate bills and to estimate your consumption when a charge is required.
  3. Financial Data such as information about when you made payments by direct debit, the amount paid, the amount refunded, the date of transactions, the bank the payment was taken from, partial information about bank details, direct debit mandate information, statuses of payments requested and refunds issued.
  4. Metering and Debt Data such as information from organisations involved in supplying your energy like your old supplier and meter operations.
  5. Contact Data such as your name and contact details may be provided to us by your landlord or estate agent or people moving in or out of a property you are living in.

We may also collect, use and share aggregated data such as usage data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this does not directly or indirectly reveal your identity.

1.4 Cookies.
We collect cookies information about you to provide you with a good experience while you use our website. Our third party providers may also use cookies to collect information about you for example when you set up direct debit mandate. Please see our cookies policy for details.

1.5 Providing personal data.
Where we need to collect personal data by law or under the terms of your contract, and you fail to provide the data when requested, we may not be able to provide you with one or more services.

2 What we do with the information you give to us.
We will only use your personal data when the law and energy regulation allows us to.

Most commonly we will use your personal data to do the following.

  1. provide you the services you have selected.
  2. where we need to comply with a regulatory or legal obligation.
  3. for our legitimate business interests.

We have set out below a description of how we plan to use your personal data and the legal/regulatory bases for doing so.

 

Purpose Type of Data Basis of processing
To register you as a customer Identity, contact, financial Perform our contractual obligation to you.
Manage payment Identity, contact, financial To run our business or recover debt.
Correspondence Identity, contact Provide continuous support
Correspondence Call records Training and monitoring.

Investigate complaints or disputes

Bill you Identity, usage, contact, financial Perform our contract obligation to you, to run and grow our business
Supply Technical, contact, personal Perform our contractual obligation to you.

 

You agree that we (and our agents) may use the information and contact details you give us or use with us, and the contact details provided when you contact us, to do any of the following things:

(a)      to set up, monitor and manage your account, including carry out our rights and responsibilities under the contract, contact you in relation to your energy supply, to transfer your account to another supplier, and share information about your account with any of our agents and other organisations and people who we use to help run our businesses (for example, meter readers);

(b)      to keep to all relevant laws, regulations, industry codes and government instructions, and to deal with any complaints;

(c)       to take a deposit, carry out credit checks, trace and recover debt, and help prevent fraud and loss; and

(d)      to help us to improve the way we run any existing and future accounts, services and products and to tell you about improvements and new products and services.

3. Sharing your information
We may share your information with selected service providers to process information we hold about you on our behalf or as otherwise required by law.  This includes but not limited to.

  1. Service providers, other energy suppliers for the performance of any contract we enter into with them or you, including (but not limited) to:
  2. Market Regulators such as Ofgem and consumer protection organisations like Energy Ombudsman and Citizen’s Advice Bureau where are obliged to do so.
  3. Direct Debit Payment providers to facilitate direct debits
  4. Meter services providers to provide meter reader functions.
  5. Prepayment services providers to provide electricity and gas prepayment functions.
  6. Cash payment providers to provide over the counter payment functions.
  7. Meter Agencies to provide meter installation and meter management functions.
  8. Local distributor to act in capacity of safe guarding your interest when there is a power cut especially when you register with us under the priority service
  9. Mailing service providers to provide paper bills printing and mailing service.
  10. Analytics and search engine providers for example Google to assist us in optimisation and improvement of our site.

We permit third-party service providers to process your personal data for specified purposes only and in accordance with our instructions.

You agree to us sharing your information with other people or organisations where necessary for the purposes of the 
contract.  This includes sharing your information with any joint account holders or anyone you have a joint bank account (that you use to set up the Direct Debit with us).  We may also exchange information between any of your energy accounts, and if we need to change agents (for example,meter readers) they may also need to share your details with the agent replacing them, and you agree to that.


4. Your rights.
You have rights as an individual which you can exercise in relation to the information we hold about you:

  • Data Update or correction of personal information: You can log into your self service account.
  • Delete your personal information. We will delete any information that we no longer need to hold, but in some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms especially in compliance to our legal and regulatory obligations.
  • To confirm if we are using your personal information or see what we hold, please contact us with the subject line “Subject Access Request”.
  • To restrict processing of your personal data, object to processing or withdraw consent to process data, you can email us at privacy@iresa.co.uk

We will respond to your request within at most 1 month but we will need to positively identify you before we action these requests. If you want further information about your rights, please contact the Information Commissioner’s Office (https://ico.org.uk), the supervisory body that regulates handling of personal information.

5. Securing your information

  • Your account is protected for your privacy and security through your email address and password. Iresa and any of our agents will never ask you for your password.
  • Access to the information we hold about you through telephone conversation is protected by 3 responses that you have chosen when you first signed up for an energy contract. We ask for this information any time you call us on phone.
  • We restrict access where possible to people who need to process your information and are subject to contractual confidentiality requirements.

 

6. Data Retention
We will store your personal data for as long as is necessary to fulfill the purposes outlined in this privacy. We are however still bound by the following retention periods:

  1. Statutory retention periods for accounting records as set by the Companies Act and HM Revenue & Customs (HMRC).
  2. The Minimum regulatory retention requirements as set by OFGEM
  3. The retention periods set by the TRAS Fraud Prevention Agency.

Where our retention periods are not bound by legislation, our policy is based on commercial justification. These includes:

  1. Compliance with our Supplier Licence Conditions.
  2. Disputes or complaints resolution.
  3. Fraud detection and prevention.

In some cases we may anonymise your personal information so that it can no longer be associated with you and use this indefinitely without further notice.

7. Out of the EU
Some of our external third parties are based outside the European Economic Areas (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by:

  1. Restricting transfer to countries that have been deemed to provide an adequate level of protection for personal data by the European commission.
  2. Using specific contracts approved by the European commission which give personal data the same protection as in Europe.

 

8. Changes to this Privacy Notice.
We may update this privacy notice from time to time to ensure it is always up to date and accurate. If appropriate we will notify you of any significant changes by email.  Your continued use of our services will mean that you accept and agree to any changes on this Privacy policy.

 

Last Updated: 25th May, 2018